Overview (Program Summary)
A program hosted by:
ACC Central OhioSEC Rule 21F-17 prohibits companies and any person from taking any action to impede an individual from communicating directly with the SEC about a possible securities law violation, including enforcing or threatening to enforce a confidentiality agreement with respect to such communications.
Since 2015, the SEC has interpreted “impede” and “confidentiality agreements” very broadly to find violations of SEC Rule 21F-17. Under the Biden Administration, the SEC’s enforcement activity has picked up significantly, and has even included enforcing Rule 21F-17 violations against several private, non-publicly traded companies. The financial penalties the SEC has assessed for such violations have included six, seven and, more recently, even eight figure dollar amounts.
This seminar will discuss these more recent enforcement actions and will identify the types of confidentiality agreements and policies companies should review—and revise as needed—to make sure they are in compliance with Rule 21F-17.
Speakers
Kevin E. Griffith, Shareholder | Co-Chair, Whistleblowing, Compliance and Investigations Practice Group
Andrew Klaben-Finegold, Associate
Notes
Registrants will need to create an account with Littler’s webinar platform, BeaconLive, in order to register and attend. This is for the purpose of tracking and containing CLE credit for the event and registrants will ONLY receive emails related to this webinar (no additional promotions or messaging from Littler or BeaconLive).
CLE
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